Martha C. v. Frank Bisignano

Summary

The United States District Court for the Northern District of Illinois reviewed the denial of Martha C.’s applications for supplemental security income and disability insurance benefits. The court held that the Administrative Law Judge adequately evaluated Plaintiff’s subjective symptoms, mental impairments, residual functional capacity, and claimed fibromyalgia under the substantial-evidence standard. The court denied Plaintiff’s request for reversal or remand and granted the Commissioner’s motion for summary judgment.

Holdings

1. The ALJ reasonably evaluated Plaintiff's subjective symptoms by considering them alongside objective medical evidence, treatment effectiveness, daily activities, and other record evidence; the determination was not patently wrong.
2. The ALJ adequately considered Plaintiff's mental impairments and reasonably omitted mental limitations from the RFC because the impairments caused no more than minimal functional limitation and the record contained no supported mental workplace limitations.
3. The ALJ did not err in finding that Plaintiff's alleged fibromyalgia was not a medically determinable impairment because the record did not establish the required fibromyalgia findings or show symptoms attributable only to fibromyalgia rather than other impairments.

Questions Presented

1. Whether the ALJ's evaluation of Plaintiff's subjective symptoms was patently wrong or unsupported by substantial evidence.
2. Whether the ALJ adequately considered Plaintiff's nonsevere anxiety and depressive disorders when determining her residual functional capacity.
3. Whether the ALJ erred in finding that Plaintiff's alleged fibromyalgia was not a medically determinable impairment and in failing to impose additional RFC limitations based on fibromyalgia-related symptoms.

Disposition

affirmed